Attachment Ligado - Request for

This document pretains to SAT-MOD-20101118-00239 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2010111800239_1220332

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                                                      April 28, 2017

                                                                                 Accepted / Fileo
  Marlene H. Dortch
  Secretary                                                                           APR 28 2017
  Federal Communications Commission                                        Fea                |
  Office of the Secretary                                                        e’a’gg{é’é”ol;flt'fifg%ns Commission
  445 12th Street SW                                                                              6 secretary
  Washington, DC 20554

                  Re: IB Docket No. 08—184 and IBFS File No. SAT—MOD—20101118—00239

  Dear Ms. Dortch:

  Ligado Networks Subsidiary LLC ("Ligado")‘ hereby submits this combined semi—annual
  report pursuant to the Memorandum Opinion and Order and Declaratory Ruling adopted
  by the Commission on March 26, 2010 in IB Docket No. 08—184 (the "MO&O"), and
  quarterly report pursuant to the Order and Authorization adopted by the Commission on
  January 26, 2011 in IBFS File No. SAT—MOD—20101118—00239 (the "O&A") (collectively,
  the "Orders"). By separate letter, Ligado requests confidential treatment of this report.

  On February 15, 2012, the Commission released a Public Notice seeking comment on
  the letter sent to it on February 14, 2012 by the National Telecommunications and
  Information Administration‘s (NTIA)." The Public Notice addressed certain issues
  related to the potential incompatibility of GPS receivers with Ligado‘s planned
  operations, and recommended vacating the Commission‘s Conditional Waiver Order
  and modifying Ligado‘s satellite license to suspend indefinitely its ATC authority.

  The Conditional Waiver Order itself provides that Ligado and members of the GPS
  industry must resolve certain outstanding issues "before Ligado commences offering
  commercial service pursuant to [the waiver granted in the Conditional Waiver Order] on
  its L—band MSS frequencies."" in light of the Commission‘s Public Notice and the
  unresolved condition in the Conditional Waiver Order, Ligado is not yet providing

  ! See Letter from Jeffrey J. Carlisle, Executive Vice President, LightSquared GP Inc., to Marlene H.
  Dortch, Secretary, FCC (July 20, 2010) (notifying the Commission that SkyTerra had changed its name to
  LightSquared); Letter from Jeffrey J. Carlisle, Executive Vice President, Ligado Networks Subsidiary LLC
  to Marlene H. Dortch, Secretary, FCC (Feb. 11, 2018) (notifying the Commission that LightSquared had
  changed its name to Ligado Networks).
  2 See Public Notice: International Bureau Invites Comment on NTIA Letter Regarding LightSquared
  Conditional Waiver, IB Docket No. 11—109, DA 12—214 (Feb. 15, 2012).
  ° LightSquared Subsidiary LLC, 26 FCC Red 566, at 41 (2011).


  ©   0   0   0   e                 10802 Parkridge Boulevard, Reston, VA 20191       |_   ligado.com                 1


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  commercial service using its ATC authority. Ligado remains committed to working
  cooperatively with Congress, federal government agencies, and the GPS industry to
  address the concerns raised by the GPS industry and others.

  Beginning in September of 2012, Ligado made a series of filings with the Commission
  proposing solutions that would allow it to deploy terrestrial broadband service in a way
  that ensures that GPS receivers are compatible with Ligado‘s operations. These filings
  have been accepted by the Commission and all have been placed on public notice for
  comment.*
  SITE DEVELOPMENT

  As a result of the Commission‘s Public Notice of February 15, 2012, Ligado has not
  undertaken any significant site development activity related to the provision of two—way
  terrestrial mobile service during this reporting period." Ligado has focused its efforts on
  resolving the underlying spectrum and deployment issues identified by the Commission
  through the series of filings referenced above.

  DEVICE MANUFACTURERS

  Qualcomin Incorporated has integrated L—Band LTE technology in its chipset roadmap
  and has developed an advanced satellite air interface technology to enable the satellite
  mode of operation in mobile devices.

  SATELLITE

  Each of the satellites operated by Ligado has performed nominally and as expected
  over the past six months.

  PARTICULAR REPORTING REQUIREMENTS

      1. Pursuant to reporting requirement IIl.A of the O&A, Ligado reports that as of
         March 31, 2017 there were approximately            terminals and approximately
         _ active private network customers on its MSS—only network. Ligado can
         only provide an estimate of the latter figure because the company does not have
         direct access to the subscriber counts of its wholesale customers. As noted
         above, Ligado is not yet providing commercial MSS/ATC or terrestrial—only
         services. Accordingly, the number of reportable active terminals and active users
         on its network in these categories is zero. As the terrestrial network is not yet in



  * See Public Notice, Federal Communications Commission Invites Comment on LightSquared Request to
  Modify Its ATC Authorization, DA 12—863 (rel. Nov. 16, 2012); Public Notice, Consumer & Governmental
  Affairs Bureau Reference Information Center Petition for Rulemaking Filed, RM No. 11683 (rel. Nov 16,
  2012).
  ° Ligado has implemented a one—way DVB—H network in the 1670—1675 MHz band.


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              commercial service, the number of reportable total bytes carried by Ligado‘s
              terrestrial network also is zero (see Condition 3 to the MO&O).

      2. Pursuant to reporting requirement III1.B of the O&A, Ligado provides the following
         list of components available from mainstream component suppliers to support L—
         band dual mode operations:




                                                                 Sincerely,



                                                                     1J_ W,\%m\r\
                                                                 William Davenport
                                                                 Senior Vice President & Deputy General
                                                                 Counsel, Regulatory Affairs


co:           Brendan Carr
              Tom Sullivan
              Jennifer Gilsenan
              I1B—SATFO@fcec.gov




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Document Created: 2017-05-11 15:13:41
Document Modified: 2017-05-11 15:13:41

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